United States v. Bhagat Singh Thind
United States v. Bhagat Singh Thind is a landmark case in U.S. immigration law that highlights the complexities of racial classification and citizenship. Bhagat Singh Thind, an immigrant from the Punjab region of India, sought naturalization in the United States, believing he fit the criteria established by previous legal precedents, particularly the definition of "white persons" as synonymous with "Caucasian." Despite anthropological classifications placing North Indians within the Caucasian race, the Supreme Court ruled unanimously that Thind did not qualify as a "white person" in the context of common understanding at the time. Justice George Sutherland’s opinion emphasized that the historical intermixture of blood with Asian races disqualified Thind from citizenship. This ruling not only denied Thind's naturalization but also reinforced restrictive immigration laws that affected individuals of Indian ancestry, including land ownership restrictions in California. The decision exemplified the racial biases embedded in legal interpretations during that era. Ultimately, the ruling was reversed in 1946 by the Luce-Celler Bill, which allowed Indians to become naturalized citizens. This case remains significant in discussions about race, identity, and immigration policy in the United States.
On this Page
Subject Terms
United States v. Bhagat Singh Thind
The Case: U.S. Supreme Court decision concerning naturalization
Date: Decided on February 19, 1923
Significance:In an interpretation of the immigration laws, the Supreme Court held that immigrants from India were ineligible to become naturalized citizens, and since the decision classified Indians as Asians, it eliminated a number of legal rights that immigrants from India had previously enjoyed.
Bhagat Singh Thind, a resident of Oregon, was an immigrant from the Punjab region of northwestern India. When he applied for naturalization in the United States, he appeared to have a good chance of having his application accepted. Although U.S. immigration law had since 1790 restricted naturalization to “white persons,” in the previous year’s case of Ozawa v. United States the U.S. Supreme Court had defined the term as synonymous with the word “Caucasian.” Anthropologists at the time classified people of northwestern India as belonging to the “Caucasian race.” It was also relevant that Thind was a person of light complexion and a member of a high caste, which meant that his ancestors had presumably been Aryans who spoke an Indo-European language.
Nevertheless, in Thind’s case the U.S. Supreme Court held unanimously that immigration laws did not permit any persons of Indian ancestry to become naturalized citizens. In the official opinion for the Court, Justice George Sutherland wrote that such an individual was not a “white person” as used in the “common speech . . . interpreted in accordance with the understanding of the common man.” Although high-caste Indians in the Punjab had historically attempted to preserve the “purity of Aryan blood,” Sutherland wrote that they had not been entirely successful, so that there had been an “intermixture of blood” with Asian races. Because the decision classified Indians as Asians, they henceforth fell under the restrictions of the California Alien Land Law, making it illegal for them to own land in the state. In addition, A. K. Mozumdar, the first person of Indian origin to have been naturalized, had his citizenship revoked. The Thind ruling was overturned by the Luce-Celler Bill of 1946, insofar as it extended the privilege of naturalization to Indians.
Bibliography
Hyung-chan, Kim, ed. Asian Americans and the Supreme Court: A Documentary History. Westport, Conn.: Greenwood Press, 1992.
Rangaswamy, Padma. Indian Americans. New York: Chelsea House, 2007.